PCAOB Release 2003-011F Frequently Asked Questions ...

1 1666 K Street NW Washington, DC 20006 Office: (202) 207-9100 Fax: (202) 862-8430 PCAOB Release 2003-011F Frequently Asked Questions regarding registration with the Board December 4, 2017 The Mechanics of registration 1. How can my firm apply for registration with the Board? To apply for registration with the Board, your firm will have to go to the Board s Web site at , access the Board s secure, Web-based system, complete the registration application, and submit the application to the Board electronically. The first step in registering is to request a user name and password to gain access to the Board s Web-based system. Firms submit this request by completing an online Entitlement Request Form, which is accessible by clicking the Register, Withdraw or Report button located on the Board s home page and following the instructions as a New User. The entitlement request form requires a firm to provide basic information about itself, and create a user ID and password.

2 Once completed, the firm will receive a document, containing a confirmation code, reflecting the firm s submitted request for access; this document relates only to system access and does not mean that the firm is registered. This document means that the firm s request for access to the Board s system has been received. If the request is approved, the firm will receive an email directing it to log into the Board s web-based system to complete its Form 1 (the registration application). The Form 1 registration application may be completed as a web form, or by using XML, as discussed in FAQ #3 below). Firms do not have to complete and submit the form immediately after accessing the system. Firms may save the Form 1 application in the Board s system and return to it at a later time to complete and submit it. A tutorial on how to complete a web form in the Board s system, as well as a sample Form 1 and General Instructions on the form, are available on the Board s Web site at After Form 1 is submitted, your application will be processed by the registration system, and an invoice will be generated.

3 Processing of your application can take up to 24 hours, after which you can come back to the registration system to view and pay your invoice via a provided link. Once you've paid, your application will be deemed submitted. PCAOB Release 2003-011F Frequently Asked Questions regarding registration with the Board December 1, 2017 Page 2 of 13 2. Is the Web-based registration system the only way to receive or submit Form 1? Yes. You cannot submit a completed Form 1 other than through the Board's Web-based system. If you would like to see a description of the information Form 1 will require, you may view the Board's registration Rules by going to 3. What formats will the system accept? What software do I need to properly prepare and submit Form 1? To properly communicate with the Board's system, you will need Internet Explorer or later.

4 To complete Form 1, you may fill it out online as a web form, or you may submit it in XML. If you have large amounts of information going into Form 1, you may find that XML is a more convenient way to submit the data because you would be able to load the data into your XML file directly or indirectly from other databases. If you would like to make your submission in XML, you must download the XML Schema from the Board s system and reference the XML instructions that are also available within the system. Using XML will likely require the assistance of a programmer who is versed in that computer language. The Board s system allows you to view your Form 1 as a PDF, and provides important guidance on the software you will need to view the PDF properly. Form 1 may require you to submit various documents to be labeled as exhibits.

5 The system will accept exhibits in PDF, GIF or JPEG format. You can convert text documents or scan documents for submission, as long as they are submitted in PDF, GIF or JPEG. 4. [FAQ # 4 has been deleted because it is no longer applicable.] 5. How much will it cost to apply for registration and when will payment be due? The registration fee will be computed individually for each firm submitting a Form 1 and will be based on the number of issuer clients that an applicant audited during the preceding calendar year. (See FAQ #8 for a discussion of the term "issuer".) A table showing this fee is set forth below. PCAOB Release 2003-011F Frequently Asked Questions regarding registration with the Board December 1, 2017 Page 3 of 13 Preceding Year Issuer Clients Fee 0-49 $500 50-100 $3,000 101-1000 $29,000 1001 and up $390,000 Payment is due at the time of submission of the application.

6 Pursuant to rules of the Board, the Form 1 will not be deemed "submitted" and review of the application will not begin until the applicant has paid the registration fee to the Board. 6. How can I confirm that the Board has received my firm s registration application? The Board has posted on its Web site a list of the firms from which it has received registration applications and will update this list periodically. After an application for registration is approved, the Board will make the application itself available on its Web site, redacting any part of the application as to which a request for confidential treatment is pending or has been granted. If an application is disapproved, the Board will post the application on its Web site, redacted as necessary, with an indication that it has been disapproved. The Board's Web site also contains a current list of all registered firms.

7 7. How does my firm request confidential treatment for some information that it plans to submit? For information contained in the Form, you will need to check a box labeled "CR" for each piece of information that you want to be treated confidentially. You need to remember that when you check a box for confidential treatment, you have requested confidential treatment only for the particular entry associated with that box. If you wish to request confidential treatment for a series of entries for example, for all entries related to a particular non-public disciplinary proceeding you must check all "CR" boxes for entries related to that proceeding. Requesting confidential treatment of a portion of a text exhibit to Form 1 requires you to submit two versions of the exhibit one version should contain all the information in the exhibit and the other version should redact those portions of the exhibit as to which you are seeking confidential treatment and show with a notation each redaction that has been made.

8 For each request for confidential treatment, you must attach, as Exhibit , the information required by PCAOB Rule 2300(c)(2), which includes a representation that, to the applicant s knowledge, the information for which confidential treatment is PCAOB Release 2003-011F Frequently Asked Questions regarding registration with the Board December 1, 2017 Page 4 of 13 requested has not otherwise been publicly disclosed and either (1) a detailed explanation of the grounds on which the information is considered proprietary or (2) a detailed explanation of the basis for asserting that the information is protected by law from public disclosure and a copy of the specific provision of law that the applicant claims protects the information from public disclosure. If you attach an Exhibit that fails to include this information, your request for confidential treatment may be denied solely on the basis of that failure.

9 Unless the firm requests otherwise by checking the specified box in Part X of its Form 1, the Exhibit will be afforded confidential treatment. registration Requirements 8. None of my firm's audit clients are "public companies." Does my firm have to register with the Board? May my firm register even if not required to do so? The Sarbanes-Oxley Act (the Act ), and PCAOB Rules provide that a firm must be registered to prepare or issue, an audit report with respect to any issuer as that term is defined in PCAOB Rule 1001(i)(iii). It is important to review the definition of "issuer" in making your determination as to whether your firm has to register because the definition may differ from what you view as a public company. The Act and PCAOB Rules also provide that a firm must be registered to prepare or issue an audit report with respect to a broker or dealer, as those terms are defined, respectively, in PCAOB Rules 1001(b)(iii) and 1001(d)(iii).

10 The Act and PCAOB Rules also provide that a firm must be registered in order to play a substantial role in the preparation or furnishing of an audit report with respect to an issuer, broker, or dealer. PCAOB Rule 1001(p)(ii) defines substantial role. The Board recognizes there are reasons that firms that currently perform no audit work for issuers, brokers, or dealers might choose to register even though not required to do so by the Act or PCAOB Rules. Some regulators have adopted rules requiring persons subject to their jurisdiction to use PCAOB -registered firms for specified services unrelated to audits of issuers, brokers, or dealers. In addition, firms that currently do no audit work for issuers, brokers, or dealers might register with the PCAOB just to be in a better position to compete for future business for which registration is required.